jurisdiction of the Catholic Church and in view of the abandonment of the sacrament of confession as practised before the Reformation, one may fairly presume that, from the date of that event, confession would no longer have been regarded as a ground from motives of public policy, entitling to an exemption from the principle of the disclosure of all the truth known about the cause, were it to be civil or criminal. Important cases and decisions Du Barré v. Livette In the case of Du Barré v. Livette (1791) Peake 77, Lord Kenyon again held that the privilege would extend so as to preclude an interpreter between a solicitor and a foreign client from giving evidence of what had passed. In the report of that case the plaintiff's counsel informed the court that Mr. Justice Buller had recently tried on circuit a case (R v. Sparkes) and that the prisoner, in that case, was a "papist" and that it came out at the trial that he had made a confession of his capital crime to a protestant clergyman. This confession had been received in evidence by the judge and the prisoner was convicted and executed. The Catholic Encyclopedia contends that it is "obvious" that neither of the parties could have regarded the confession as sacramental. Lord Kenyon said that he would have paused before admitting such evidence, adding Butler v. Moore In this case a priest was imprisoned for contempt of court for refusing to answer whether John Butler, 12th Baron Dunboyne, professed the Catholic faith at the time of his death. Statute would have nullified Lord Dunboyne's will had such been the case. Butler v. Moore was an Irish case (Ireland at the time formed part of the United Kingdom, but had a separate legal system). R v. Redford In 1823, in the case of the R v. Redford, which was tried before William Draper Best, 1st Baron Wynford, Chief Justice of the Common Pleas on circuit, when a Church of England clergyman was about to give in evidence a confession of guilt made to him by the prisoner, the judge checked him and indignantly expressed his opinion that it was improper for a clergyman to reveal a confession. R v. Gilham The case of R v Gilham (1828) 1 Mood CC 186, CCR, concerned the admission of evidence against a prisoner of an acknowledgment of his guilt which